Round Hill Music LP (“Round Hill” or the “Investment Manager”), a Delaware limited partnership,
was founded in January 2011 and is a boutique music publishing firm headquartered in New York.
Additionally, Round Hill has been an exempt reporting adviser registered with the US Securities and
Exchange Commission (“SEC”) since March 2013. Effective June 2015, Round Hill became an SEC-
registered investment adviser.
Round Hill currently provides discretionary investment management services to Round Hill Music
Royalty Fund LP (“Fund I”), Round Hill Music Royalty Fund II LP (“Fund II”) and its affiliates, Round
Hill Music Royalty Executive Fund A LP (“Executive Fund A”), and Round Hill Music Royalty Executive
Fund B LP (“Executive Fund B”; each an “Executive Fund or collectively the “Executive Funds”); as
well as Round Hill Music Carlin Coinvest LP (“Carlin Coinvest”) and Round Hill Music Motown
Coinvest, LP (“Motown Coinvest” collectively with Fund I, Fund II and the Executive Funds, “the
Funds”). The general partner of the Fund I, the Executive Funds, the Carlin Coinvest and the
Motown Coinvest funds is Round Hill Music Royalty Fund GP LP, a Delaware limited partnership (the
“General Partner”); whereas the general partner of Fund II is Round Hill Music Royalty Fund GP II LP,
a Delaware limited partnership (“GP II LP”, together, with the General Partner, the “General
Partners”) Joshua Gruss is the initial principal of both General Partner entities (the “Principal”).
Fund investors will hereby be defined as (the “Limited Partners”). The respective General Partner
may, in its sole discretion, provide or commit to provide co-investment opportunities to one or more
Limited Partners in the Funds, and/or other persons from time to time in connection with the
potential acquisition of the copyright assets and such other activities incidental or ancillary thereto.
See Item 5 and Item 10 for further discussion.
Mr. Gruss is joined by Neil Gillis, Richard Rowe and Amanda Siconolfi, an experienced team with an
established reputation and a strong track record in the music and finance industries (collectively, the
“Investment Team”). Their deep networks in the music and entertainment industry are expected to
provide access to unique proprietary opportunities and enhance Round Hill’s ability to create value
for the Funds’ catalogs. Round Hill will capitalize on the team’s unique combination of music
industry, institutional investment and finance experience to differentiate itself in an industry
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dominated almost exclusively by music professionals.
Please see Item 8 below for a brief discussion of Round Hill’s current investment strategies
(collectively, the “Strategies”). Important information regarding an investment in the Funds,
including the specific investment strategies and policies, fees and expenses, risk factors and other
material terms, are set forth in the Private Placement Memorandum and Partnership Agreement
(collectively, the “Offering Documents”).
As of December 31, 2018, Round Hill’s discretionary regulatory assets under management were
approximately $563,393,792.
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Round Hill Music Royalty Fund LP and Round Hill Music Royalty Fund II LP Commencing on
the Effective Date (defined below) and during the Investment Period (defined below), Fund
I and Fund II, respectively, will pay the General Partner an annual management fee (the
“Management Fee”), payable quarterly in advance, equal to 2.00% for Fund I and 1.75% for
Fund II of aggregate commitments. Commencing with the earliest to occur of (i) the first
Management Fee due date after the expiration of the investment period, (ii) the date the
General Partner or its affiliates first receives or begins to accrue Management Fees with
respect to a successor fund, or (iii) the date that is 180 days after the Fund(s) is first placed in
Continuity Mode (as defined in the Partnership Agreement) (unless the Fund(s) is removed
from Continuity Mode in accordance with the Partnership Agreement):
the Management Fee for Fund I will equal 2.00% of (i) the aggregate investment
contributions, less (ii) the aggregate amount of investment contributions with respect
to the portion of each investment that has been disposed of or completely written off.
the Management Fee for Fund I shall be reduced to 1.5% per annum reductions as
detailed in the respective Partnership Agreement.
the Management Fee for Fund II will equal 1.75% of (i) the aggregate investment
contributions, less (ii) the aggregate amount of investment contributions with respect
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to the portion of each investment that has been disposed of or completely written off.
the Management Fee for Fund II shall be reduced to 1.5% per annum reductions as
detailed in the respective Partnership Agreement.
In the event that the term of Fund I and/or Fund II is extended beyond its initial 10 year term,
the Management Fee is subject to further reductions as detailed in the respective
Partnership Agreement.
The Management Fee will be reduced by: (a) 100% of any directors’ fees, financial consulting fees or
advisory fees paid to the General Partner with respect to any Fund investment; (b) 100% of any
transaction fees paid to the General Partner with respect to any Fund investment; and (c) 100% of any
break-up fees with respect to Fund transactions not completed that are paid to the General Partner;
but not including, in any event, any amount received by the General Partner or other person from a
portfolio entity as reimbursement for expenses directly related to such portfolio entity, or as
payment for services provided to any portfolio entity in the ordinary course.
At the end of the period (the “Investment Period”) commencing on the initial closing date and
ending on the fifth anniversary of the later of the final closing date and the date as of which the
respective General Partner notifies the Limited Partners that the Principal has actively commenced
reviewing investment opportunities for the Funds other than the Investor Group Investments (the
“Effective Date”), all Partners will be released from any further obligation to fund investments,
except to the extent necessary to: (i) cover expenses, liabilities and obligations of the Fund,
including Management Fees; (ii) fund pre-existing commitments and complete investments by the
Funds in transactions that were in process or under active consideration as of the end of the
Investment Period; and (iii) effect follow-on investments in existing portfolio assets.
Except as otherwise provided in the Offering Documents, income, expenses, gains, and losses of
Fund I and Fund II, will generally be allocated among the Limited Partners in a manner consistent
with the distribution of proceeds described.
The General Partner of each fund will pay all ordinary administrative and overhead expenses incurred
in connection with maintaining and operating its office(s), including employees’ salaries, rent,
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utilities, etc. that are not otherwise charged to Fund I and Fund II, or a portfolio entity as described
or permitted hereunder.
In addition to the Management Fee, Fund I and Fund II will pay all other fees and expenses that are
not reimbursed by portfolio entities (such reimbursements may be for travel and other out-of-pocket
expenses incurred in connection with the making, monitoring and/or disposing of such portfolio
investments, including follow-on investments and refinancings) including legal, regulatory (including
the preparation and filing of Form PF if applicable), audit and fund administration, administrators
(including but not limited to the Copyright Administrator), consulting, financing, accounting, and
custodian fees and expenses, which may be provided by one or more entities associated with or
controlled by the General Partner or the Principal on terms no less favorable than a third-party arm’s-
length basis; expenses associated with Fund I and Fund II’s, financial statements, tax returns and
Schedule K-1s; out-of-pocket expenses incurred in connection with transactions not consummated;
expenses of the Advisory Board and annual meetings of the Limited Partners; insurance (including
directors and officers insurance); other expenses associated with the acquisition, holding and
disposition of its investments, including extraordinary expenses (such as litigation, if any); placement
fees; and any taxes, fees or other governmental charges levied against Fund I and Fund II.
Fund I and Fund II’s terms, are subject to early termination upon certain circumstances as set forth in
the Partnership Agreements, including upon (i) the vote of 80% in interest of the Limited Partners to
terminate Fund I and Fund II, respectively, for any reason after the second anniversary of the final
closing of Fund I and/or Fund II, and (ii) the vote of 66 2/3% in interest of the Limited Partners to
terminate Fund I and/or Fund II, for cause.
Round Hill Music Royalty Executive Fund A LP
Executive Fund A pays the General Partner or its designated affiliate (including Round Hill) in
advance, commencing on the Effective Date, for the period from and including the Effective Date
through the end of the quarter during which the Effective Date occurs, and thereafter on a quarterly
basis in advance on January 1, April 1, July 1 and October 1 of each year (each such date, a
“Management Fee Due Date”) until the final distribution of Executive Fund A’s assets, an annual fee
(the “Management Fee”) equal to 1.5% of an amount equal to the Non-Affiliated Partners’
Percentage of the aggregate Commitments as compensation for managing the affairs of Executive
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Fund A. The Management Fee amount may be adjusted pursuant to the Limited Partnership
Agreement.
Executive Fund A along with the other Funds shall bear its pro rata share (based upon its and any
other Executive Fund’s aggregate investment) of fees and expenses that would otherwise be
Partnership expenses relating to the negotiation, consummation and disposition of each investment.
Round Hill Music Royalty Executive Fund B LP
Executive Fund B does pay any management fees.
Executive Fund B along with the other Funds shall bear its pro rata share (based upon itsand any
other Executive Fund’s aggregate investment) of fees and expenses that would otherwise be
Executive Fund B’s Expenses relating to the negotiation, consummation and disposition of each
investment.
Co-Investment Funds
The General Partner or an affiliate thereof may receive compensation for management and other
services performed in connection with co-investments made in portfolio entities. When a co-
investment vehicle is formed, such entity will bear expenses related to its formation and operation,
many of which are similar in nature to those borne by the fund(s); however, fees may vary. Certain
co-investment vehicles are not subject to such fees.
Important Note for all Funds: Greater detail regarding fees and expenses, as well as other important
information regarding an investment in any of the Funds is more fully set forth in the Fund Offering
Documents and/or Limited Partnership Agreement.
August 2019 9
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Round Hill does not accept performance-based fees – that is, fees based on a share of capital gains
on or capital appreciation of the assets of a fund.
The Principal currently manages other investments in addition to the Funds and may devote a
portion of his time to the management of such investments. In addition, the Principal may spend a
portion of his business time and attention pursuing investment opportunities that do not fall within
the investment objectives of Fund I and/or Fund II
Round Hill’s investment staff will continue to manage and monitor such investments, although the
Principal expects that the time required to do so will be significantly less than will be spent on Fund
matters, and the Principal expects to devote substantially all of his business time and attention to
the affairs of the Funds, its portfolio entities and assets, any alternative investment vehicles, any co-
investment or other vehicles, the management company and its affiliates, and the respective
successors and affiliates of each of the foregoing. The General Partners believe that the significant
investment of the Principal in the Funds, as well as the Principal’s interest in the carried interest,
operate to align, to some extent, the interest of the Principal with the interest of the Partners;
although the Principal has economic interests in such other investments and receives management
fees and carried interest (or other similar incentive fees) relating to these interests. Such other
investments that the Principal may control may compete with the Funds or assets acquired by the
Funds.
There can be no assurance that an investment opportunity that comes to the attention of the
Principal that is appropriate for the Funds will be referred to the Funds. At such time as the General
Partner of each fund is permitted to raise a successor investment fund where the Principal will
continue to manage the Funds’ investments, but also may, and likely will, focus investment activities
on other opportunities and areas unrelated to the Funds’ investments. Certain investments may be
allocated between the Funds, and any successor or predecessor fund in a manner as set forth in
each fund’s operating agreements.
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To the extent that the General Partner determines from time to time in the conduct of the Funds’
affairs to utilize the services of, otherwise engage in business activities with, and/or make payments
to affiliates of the General Partner or the Principal, such services, activities and payments may
present an actual or potential conflict of interest for the General Partner or the Principal but in any
event are anticipated to be an arm’s-length basis and will be subject to the terms and conditions of
Fund I and Fund II’s Agreements.
The General Partner will be subject to additional potential conflicts of interest, including as a result of
the fact that services may be provided to the Funds by affiliates of the General Partner. For example,
the Funds may engage a Copyright Administrator who is an affiliate of the General Partner and such
Copyright Administrator will provide copyright administrative services with respect to the portfolio
held by the Funds. While the fees paid to an affiliated Copyright Administrator will not exceed the
fees that would be paid to an equally qualified (as determined by the General Partner) third party,
such compensation will not be determined through arm’s length negotiations and the General
Partner will not guarantee the performance by its affiliates of any services provided to the Funds. In
addition, an affiliated Copyright Administrator may also provide services to and earn fees from
entities not affiliated with the Funds. In such a case, there may be substantial requirements imposed
on the time, attention and resources of the Copyright Administrator.
The Executive Funds have been organized for the principal purposes of making investments side-by-
side with Fund I and engaging in such other activities incidental or ancillary thereto Round Hill deems
necessary or advisable.
See below Item 7 – Our Clients for more information
Round Hill has designed and implemented procedures to ensure that all Clients are treated fairly and
equally. See also Item 8, Methods of Analysis.
August 2019 11
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Round Hill provides discretionary investment management services to the Funds.
Further, the General Partner of each Fund created one or more investment entities to invest
alongside Fund I and Fund II for certain Limited Partners associated with the Principal, including,
without limitation, certain employees of the General Partner and/or its affiliates, executives of
companies in which the Principal has previously invested, been employed or otherwise been
associated, etc. The terms of these entities may be more or less favorable to the Limited Partners
therein than the terms offered to the Limited Partners in Fund I and/or Fund II.
In its discretion, Round Hill may enter into side letter arrangements with certain investors in Funds
managed by Round Hill (“Side Letter Investors”) whereby Round Hill and a Side Letter Investor have
agreed (or may agree in the future) to vary the Side Letter Investor’s investment terms from those
made available to other investors in Funds. Round Hill has entered side letter arrangements in the
past, but as of the date of this Brochure, all investment terms have been extended to all investors in
Fund I and/or Fund II.
In its discretion, Round Hill, may enter into additional side letters or other similar agreements with
certain Limited Partners that have the effect of establishing rights under, or altering or
supplementing the terms of the Partnership Agreement.
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Methods of Analysis
Round Hill adheres to strict acquisition criteria and will utilize a cautious approach to portfolio
construction in order to mitigate downside risk. The Investment Team believes that downside risks
will be reduced by: (i) portfolio diversity which prevents concentration in any single artist, genre or
musical era; (ii) iconic assets that have enduring value and experience consistent usage; (iii) a
historically active marketplace for buyers of intellectual property which facilitates opportunities for
strategic sales and liquidity; (iv) global copyright protection and enforcement which reduces the
August 2019 12
typical legal risks associated with intellectual property assets; and (v) long-term royalty rates that are
established through federal law or judicial processes. Round Hill will seek to capture upside by
acquiring catalogs that have been under-exploited and by implementing broad value creation
initiatives.
Music publishing assets offer attractive, risk-adjusted returns and regular, inflation-protected cash
flows. They generally generate an annuity-like stream of revenue due to the predictable patterns of:
(i) usage from established rights catalog; (ii) contractual terms with long tenures; and (iii) life of
author plus 70-year contracts in the U.S. and comparable durations internationally. The Funds
anticipates distributing income to investors semi-annually.
Investment Strategies
As a fully integrated owner and operator of music publishing properties, Round Hill’s investment
strategy focuses on acquiring iconic copyrights with a proven place in culture, a history of stable
royalties and potential for future exploitation. Typically, Round Hill will leverage its strong reputation
and deep relationships in the music industry to purchase copyrights directly from songwriters or
third parties. By acquiring catalogs, Round Hill becomes the owner and administrator of a collection
of copyrights that generally generate regular cash flows from royalty payments. In order to enhance
the overall stability of the portfolio, the Funds will invest in a range of catalogs diversified by artist,
genre and musical era. Catalog diversity ensures that the portfolio will retain consistent cultural
relevance regardless of shifting music trends.
There can be no assurances that a Client will achieve its investment objective or that the strategies
pursued and methods utilized by Round Hill will be successful under all or any market conditions.
Risks of Investment
An investment in the Funds should be viewed as a speculative investment. It is not intended as a
complete investment program and is designed only for sophisticated Limited Partners who have
adequate means of providing for their needs and contingencies without relying on distributions or
withdrawals from their investment in the Funds, who are financially able to maintain their
investment and who can afford a loss of all or a substantial portion of their investment. There can be
August 2019 13
no assurance that the investment objectives of the strategies described above and more fully in the
Fund Offering Documents will be achieved.
Round Hill believes that the catalogs have limited downside risk because (i) the risk associated with
music content declining in popularity (“content risk”) can be mitigated by portfolio diversity; (ii)
iconic assets generally demonstrate enduring value and repeat usage; (iii) historically, an active
marketplace exists for buyers of intellectual property which facilitates exit opportunities and
liquidity; (iv) institutionalized worldwide copyright protection and enforcement exists; and (v) long-
term contractual royalty rates established by law or judicial process.
In considering participation in the Funds, a prospective investor should be aware of certain risk
factors, which include, but are not limited to, the following:
Risk of Loss. All investments risk the loss of capital. No guarantee or representation is made that an
investment in the Fund will be successful or that the Fund’s investment objectives will be met.
Investment in the Fund should be part of an overall investment strategy which prospective investors
should develop with the assistance of their own advisors.
Future and Past Performance. The performance of the General Partners’ prior investments is not
necessarily indicative of future results. While the General Partner intends for the Funds to make
investments that have estimated returns commensurate with the risks undertaken, there can be no
assurances that any targeted internal rate of return will be achieved. On any given investment loss of
principal is possible.
Concentration of Investments. Due to the Funds’ investment concentration in one industry, the
performance of a few holdings or of a particular industry may substantially affect its aggregate
return. Furthermore, to the extent that the capital raised is less than the targeted amount, the Funds
may invest in fewer portfolio assets and thus be less diversified.
Music Industry. There is significant uncertainty as to the nature and scale of the future development
of the music industry. As such, it is not certain that current royalty income sources will be maintained
or replaced with other income sources of a similar value.
August 2019 14
Limited Transferability of Fund Interests. There is no public market for the Funds’ interests, and none
is expected to develop. There are substantial restrictions upon the transferability of Funds’ interests
under the respective Partnership Agreement and applicable securities laws. In general, withdrawals
of Funds’ interests are not permitted and are not redeemable.
Copyright Ownership. Disputes regarding ownership are a risk to which the Funds may be exposed.
The royalty income arising from a copyright acquired by the Fund may be challenged by third parties
claiming rights to the same royalty income and copyright. Investments made in copyrights, master
recordings and other related rights are not perpetual rights; they expire or revert at the end of the
relevant time period. Once they expire or revert, third parties may use the rights without payment of
royalty and hence the income and value related to the relevant copyright will end.
The foregoing does not purport to be a complete explanation of the risks involved in trading
securities or with respect to any investment strategy. One should refer to the respective Fund’s
Offering Document for a complete and specific description of risks.
Note: Round Hill may add, modify and/or remove Strategies at any time pursuant to the Offering
Documents. Greater detail regarding Round Hill’s methods of analysis, investment strategies, and risk
of loss may be found in the Fund Offering Documents.
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Neither Round Hill, nor its principals or employees, has been the subject of any complaints or
involved in any disciplinary proceedings since its inception.
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The General Partners of the Funds both Delaware limited partnerships (the “General Partners”), are
also affiliates of Round Hill. The General Partners will control the business and affairs of the Funds.
August 2019 15
As described in the offering documentation of the Funds, the General Partners may, each in its sole
discretion, provide or commit to provide co-investment opportunities to one or more Limited
Partners in the Funds and/or other persons from time to time in connection with the potential
acquisition of the copyright assets and such other activities incidental or ancillary thereto. The
General Partners reserve the right at any time to accept or reject all or any portion of any
subscription in a co-investment vehicle its sole discretion. Conflicts of interest may arise in the
allocation such co-investment opportunities. The allocation of co-investment opportunities, which
may be made to one or more persons for any number of reasons as determined by the respective
General Partner, may not be in the best interests of the Funds or any individual Limited Partner. In
exercising its sole discretion in connection with such co-investment opportunities, the General
Partners may consider some or all of a wide range of factors, which may include the likelihood that
an investor may invest in a future fund sponsored by the General Partner or its affiliates. Co-
investments typically involve investment and disposal of interests in the applicable portfolio entity at
the same time and on the same terms as the Fund making the investment. However, it is possible
that for strategic and other reasons, a co-investor or co-invest vehicle may purchase a portion of an
investment from the Fund. In addition, the General Partner or an affiliate thereof may receive
compensation for management and other services performed in connection with co-investments
made in portfolio entities. When a co-investment vehicle is formed, such entity will bear expenses
related to its formation and operation, many of which are similar in nature to those borne by the
Funds. In the event that a transaction in which a co-investment was planned, including a transaction
in which a co-investment was believed necessary in order to consummate such transaction,
ultimately is not consummated, all broken deal expenses relating to such unconsummated
transaction may be borne by the Fund, and not by any prospective co-investors, that were to have
participated in such transaction.
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Personal Trading
Round Hill has a fiduciary responsibility to treat clients fairly and avoid actual or potential conflicts of
interest. The employees of Round Hill have an obligation to act solely in the best interests of clients,
August 2019 16
and to make full and fair disclosure of all material facts, particularly where the clients' interests may
conflict with the interests of Round Hill or its employees.
Code of Ethics
Round Hill strives to adhere to the highest industry standards of conduct based on principles of
professionalism, integrity, honesty and trust and therefore has adopted a Code of Ethics which
describes the general standards of conduct that it expects of all employees and focuses on specific
areas where employee conduct has the potential to adversely affect the Clients: misuse of
confidential information, personal securities trading and outside business activities. Failure to
uphold the Code of Ethics may result in disciplinary sanctions, including termination by Round Hill.
All employees must acknowledge the terms of the Code annually, or as amended. Any Client or
prospective Client may request a copy of the Round Hill Code of Ethics.
Under the Code, Round Hill’s employees are permitted to maintain personal trading accounts
provided that such accounts are disclosed to Round Hill and any personal trading by employees must
be consistent with the Code and all applicable laws. Employees may buy, sell or hold for their own
personal trading accounts securities that Round Hill also may buy, sell or hold for the private funds it
manages subject to compliance with applicable laws, rules and regulations, the Code, pre-approval
and a determination that no conflict of interest exists.
Misuse of Nonpublic Information
Round Hill’s Code also addresses misappropriation of material nonpublic or proprietary information
(e.g., insider trading) and outside business activities. Round Hill’s insider trading prohibitions (i) apply
to all employees, (ii) extend to activities within and outside their duties as employees of Round Hill,
and (iii) apply to investment interest-related information that is internal to Round Hill. Employees are
permitted to engage in limited outside business activities provided these activities are pre-cleared
and more importantly, do not create an actual or potential conflict of interest due to the amount of
time spent on such activities and the investment-related nature of certain activities.
August 2019 17
Personal Securities Trading
Subject to compliance with applicable laws, rules and regulations, and the Code, employees may buy,
sell or hold for their own personal trading accounts securities, including the same securities as Client
accounts. Round Hill has adopted personal trading policies and procedures to prevent conflicts of
interest with the Funds.
Round Hill at times may maintain a restricted list of securities that it and its employees may not trade
in order to avoid the misuse of material non-public information or confidential client information.
Round Hill’s Chief Compliance Officer and/or his/her designee periodically reviews the personal
accounts of its employees for compliance with these policies and procedures.
Outside Business Activities
Round Hill’s Chief Compliance Officer must pre-approve all outside activities conducted by a Round
Hill employee. If any activities are deemed to be in conflict with the Funds, such conflicts will be fully
disclosed.
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Round Hill, in acquiring publishing copyrights, master recording rights and other intellectual property
rights, does not engage broker dealers.
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The Funds were organized for the purpose of investing in high quality, iconic revenue producing
music publishing copyrights, master recording rights and other intellectual property rights
(“catalogs”) related to recording artists; owning, managing, supervising and disposing of such
investments; and engaging in all related activities.
Music publishing revenues are earned through the receipt of royalties related to the licensing of
rights in musical compositions, the sale of public sheet music and songs. The receipt of royalties
principally relates to amounts earned from public performance of copyrighted material, the
August 2019 18
mechanical reproduction of copyrighted material on recorded media including digital format, and the
use of copyrighted material in synchronization with visual images.
Therefore, the role of a music publisher is to collect these royalties internationally and work to
enhance the value of the song copyrights through commercial usage. Round Hill will seek to capture
upside by acquiring catalogs that have been under-exploited and by implementing broad value
creation initiatives. The Investment Team is supported by experienced in-house publishing
administration/royalty and creative teams of twenty professionals. These teams are responsible for
assisting with operations, administration, licensing and marketing and is instrumental in generating
outsized returns. Cash flow from under-exploited copyrights can be enhanced significantly through:
(i) improved royalty collection through Round Hill’s extensive infrastructure for capturing royalty
streams; (ii) strategic licensing; and (iii) song placement. In addition, Round Hill’s marketing
capabilities are further enhanced through its sophisticated and proprietary creative marketing
system, Publisher’s Toolbox. As a boutique publisher in a consolidated industry, Round Hill’s core
investment philosophy of active catalog management distinguishes it as an attractive alternative to
the larger players that dominate the space. Songwriters seek Round Hill for the administration of
their compositions due to Round Hill’s differentiating ability to customize its approach to value
creation for each individual catalog in its portfolio.
Additionally, a third party performs an annual fair market value analysis of the Funds’ investments,
which takes into consideration net publisher share (“NPS”) and additional factors including, but not
limited to, the investments prospective income and cash generating ability.
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The Funds acquire publishing copyrights, master recording rights and other intellectual property
rights; therefore, Round Hill does not have custody of assets as defined under Rule 206(4)-2 of the
Advisers Act.
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Round Hill has investment discretion which shall be exercised in a manner consistent with the stated
investment objectives for the Funds. See also Item 13 – Review of Accounts above.
Important information about the Funds, including the specific investment policies, fees and
expenses, and other material terms, are set forth in the Fund Offering Documents and/or Limited
Partnership Agreements.
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Round Hill does not receive proxies with regard to the acquired publishing copyrights, master
recording rights and other intellectual property rights.
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Round Hill, to the best of its knowledge and belief, does not have any financial condition that would
be likely to impair its ability to meet its commitments to its clients.
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Open Brochure from SEC website